Auditing and General Consultancy
The HSE Approved Code of Practice L8 ‘Legionnaires’ Disease (ACOP L8) – The control of legionella bacteria in water systems’ (clause 42) requires that management and communication procedures be periodically reviewed.
It is therefore beneficial to carry out regular audits of the legionella management programme to ensure:
- that control measures are continually effective and appropriate for the site
- that alternative action has been taken in the event of inconsistent results
- that all required documentation is available and up to date
- that the risk assessment remains valid
- that company procedures and methods are being followed
- that equipment is calibrated and suitable for the task
- that all in-house staff and external contractors are suitably trained and competent
- that the control methods represent value for money
- that reporting / communication structures and areas of responsibility are fully documented
For many clients this can be undertaken as an exercise together with the existing contractor or service provider however it is advisable to take a third party assessment of the level of compliance to ensure an independent and unbiased review.
CASE STUDY 1
A county council commissioned Nemco to conduct a two part review of their legionella management systems to ensure they were complying with ACOP L8.
The initial phase involved a review of the organizational policies and lead to clarification and considerable updating of many of the recommendations so that they fell in line with the current guidance.
The second phase was to establish the level of compliance at sites level. Risk assessments of a selection of sites were reviewed and site records were examined. In addition, the site personnel responsible for the regular testing were interviewed on an informal basis.
The investigations on site concluded that the policy was not being applied in all cases and there was a high degree of inconsistency in the frequency and implementation of the site monitoring. Records were not being fully completed and the site personnel were confused about the testing methods.
The audit results
- Revision and simplification of organizational policies
- Clarification of reporting lines and areas of responsibility
- Communication of the guidance to site staff
- Improved record keeping and audit trails
- Implementation of training courses for site personnel
CASE STUDY 2
An alcoholic beverage manufacturer commissioned Nemco to conduct a corporate governance review of their legionella management systems across the UK and Ireland.
The scope extended to the following:
- Audit of the company procedures against ACOP L8
- Actual practice on site and compliance with company procedures
- Inspection of the risk assessment to ensure it met with the ACOP L8.
- Inspection of site logbooks and records.
- Review of evidence that the required testing was being carried out.
- Informal interview with site staff involved in the monitoring and testing.
- Audit of the processes for reporting / dealing with non-compliance.
- Audit of the procedures for reviews / re-assessment.
- Assessment of ‘value for money ‘ from the contractors employed
The audit results
 The audit found several areas of non-compliance that were swiftly rectified (mainly in the recording procedures) and most notably, there were several areas where the company was far exceeding the statutory requirements.
By reducing the frequency of certain inspections and omitting some unnecessary sample analysis in line with the current guidance, potential savings of over £120,000 per annum were identified.
Consultancy
Nemco are able to offer practical and valuable advice at all stages of building management including:
- Assessment of building water systems plans prior to installation
- Auditing of existing legionella control programmes
- Production or review of corporate policies and procedures
- Responsible person duties as a third party if in-house personnel are not available
- Positive legionella remediation and sustained control
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